Schedule F Reporting

GW is required by the IRS to report on its activities conducted outside the United States at any time during each fiscal year on Schedule F of its annual tax return.

Activities conducted outside the United States (U.S.) include program services, grant making, fundraising, and investments. The guidance below is to assist you in determining if an activity meets the requirement for reporting on Schedule F. Expenses related to the following activities, as well as the region in which they were incurred, must be tracked in order to comply with Schedule F’s disclosure requirements.

The usage of all the foreign accounts is dependent upon the location of the activity. If the activity itself ultimately occurs outside the U.S., then the expense should be recorded in the foreign accounts. For example, a conference in Germany would require all travel expenses to be coded to the foreign accounts, whether they were purchased in the U.S. or abroad. This would include expenses such as transportation from your U.S. home to the airport on the way to the foreign destination. Any expenses incurred by non-GW personnel (i.e., consultants) traveling abroad should also go in the foreign account. On the other hand, bringing individuals or companies to the U.S. would go to the relevant domestic account.

One important thing to note – Concur generally defaults travel related expenses to the location of the airline. For example, United flights default to the U.S. accounts even if the flight is to the United Kingdom. Lufthansa defaults to the foreign accounts even if the flight is to the U.S. It is critical that faculty and staff change the default account code to ensure more accurate reporting.

Foreign Accounts and Expenditure Types:

52613 Non-US Special Events/Business Relations

53112 Non-US Other Travel and Related Expense

53145 Non-US Airfare Expense

53146 Non-US Business Meals

53147 Non-US Local Transportation

53148 Non-US Lodging

53149 Non-US Rental Car Expense

55161 Non-US Professional Services

55404 Non-US Subcontracts

55405 Subcontracts – No IDC Calc – Non-US

Type of Activity:

Program Services: For purposes of reporting activities on Schedule F, the following categories are deemed to be foreign program services. Foreign “program services” are activities conducted outside the U.S. that form the basis of the GW’s exemption from federal income tax and will generally fall into the following categories:

Educational activities: Collaboration, formal mutual agreement, coordination, or partnership with an institution outside of the U.S. to provide reciprocal activities, use of facilities or resources for achievement of common academic or scientific goals where financial expenditures were incurred.

Examples of foreign educational activities include expenses incurred for travel or other activities outside of the U.S. that are related to GW's study abroad programs, distance education courses, medical education/training exchange, or degree programs.

Note: Communications by electronic means (email, phone, or teleconference) are not considered collaborations for purposes of this definition.

Research activities: The expenditure of internal or external sponsored funds or subawards related to either basic or applied research activities outside the U.S. Basic research is aimed at gaining more comprehensive knowledge or understanding of a subject under study. Applied research is aimed at gaining the knowledge or understanding to meet a specific, recognized need or problem.

Grant making: This category includes awards, prizes, contributions, noncash assistance, stipends, scholarships, fellowships, research grants (including subcontracts, subawards, etc.), and similar payments and distributions made by GW to any particular foreign organization or entity (including a foreign government) or individual for foreign activity or to a particular U.S. organization or entity or individual for foreign activity.

Fundraising Activities: Activities undertaken outside of the U.S. to induce potential donors to contribute money, securities, services, materials, facilities, other assets, or time. This would include publicizing and conducting fundraising campaigns; maintaining donor mailing lists; conducting fundraising events, preparing and distributing fundraising manuals, instructions, and other materials; professional fundraising services; and conducting other activities involved with soliciting contributions from individuals, foundations, governments, and others. Fundraising activities do not include gaming, the conduct of any trade or business that is regularly carried on, or activities substantially related to the accomplishment of GW’s exempt purpose (other than by raising funds).

Investment activities: Investment activities should be reported on a region-by-region basis, separately from other activities in a region. Reporting is based on the legal domicile of an investment form (i.e. a foreign partnership’s legal domicile). Foreign investments indirectly held through a domestic (U.S.) pass-through entity, need not be reported, as the domicile of the pass-through entity is not a foreign location.

Region and Country List:

The IRS requires GW to report its activities by the following regions. What countries comprise each region can be found on pages 1 and 2 of the Schedule F Instructions (PDF).

Antarctica

Central America and the Caribbean

East Asia and the Pacific

Europe (including Iceland and Greenland)

Middle East and North Africa

North America

Russia and the Neighboring States

South America

South Asia

Sub-Saharan Africa

Questions may be directed to the Tax Department at 571-553-8313 or [email protected].